Mobile money services are emerging all over the world and financial regulators are unfamiliar with the money laundering and terrorist financing (ML/TF) risks arising from these new services. The current anti-money laundering and combating the financing of terrorism (AML/CFT) rules are often applied disproportionately to the risks involved, thus hampering the adoption of mobile money services amongst consumers, the poor in particular. It is, for example, disproportionate to put a high customer due diligence burden on very poor customers who are transacting very low amounts for legitimate reasons. Excessively strict ‘know your customer’ (KYC) rules can be impossible for the poor to comply with, keeping them locked into the informal economy without preventing ML/TF.